Analysis of Securities and Exchange Commission's proposed "Regulation Best Interest" for securities broker-dealers
Memorandum on how bitcoin and other cryptocurrencies are regulated in the U.S.
Analysis of relevant prudent investment factors for fiduciary investments in stable value funds
Analysis of permissibility of ESG (environmental, social, governance) investing by fiduciaries in the United Kingdom
Client memorandum on whether an institutional money market fund is a prudent investment for fiduciary cash versus a government MMF
Analysis of class action lawsuits alleging violations of ERISA by university pension plans
Series of papers on how robo-advisors are regulated, how they should be regulated, and whether they are "fiduciaries"
Paper discussing comparative risk and reward features of different types of cash sweep programs offered by broker-dealers, comparing deposit sweeps with MMF sweeps
Analysis of "robo-advisor" service structures, fee arrangements, and potential conflicts of interest
Analysis of Department of Labor fiduciary rule under ERISA and its application to regulated broker-dealers
Banking law expert in international Investor-State Dispute Settlement (ISDS) case
Analysis of legal issues raised by third party vendor relationship with bank under Bank Service Company Act and bank supervisory guidance
Analysis of eligibility of trust accounts to invest in retail money market funds
Client memorandum analyzing the extent to which cost is a component of the duty of prudence that must be considered by a fiduciary when investing fiduciary assets
Analysis of SEC final regulation on money market fund reform
Client memorandum re authority of Financial Stability Oversight Council and Federal Reserve to designate and regulate nonbank "SIFIs"
Request to Federal Reserve requesting ruling that certain government-only money market funds are "highly liquid assets" for purposes of large bank liquidity requirements
Analysis of Federal Reserve regulation adopting prudential standards for large bank SIFIs
Comment letters on SEC proposal to change regulation of money market funds
Research and analysis concerning regulation of money market funds
Client memorandum on fiduciary duties with respect to underperforming assets
Comment letters to FDIC and Federal Reserve Board concerning Reglation Q repealAnalysis of Regulation D definition of "deposit" in connection with sweep arrangementPaper on implications of financial crisis for modern portfolio theory and Uniform Prudent Investor Act Letter to FASB concerning treatment of money market funds as cash equivalents for financial statement reporting purposesComment letter on SEC proposal regarding regulation of municipal advisorsAnalysis of SEC study on treatment of securities brokers as fiduciariesConceptualizing proposal for regulatory treatment of principal trades by broker-dealersAnalysis of regulatory criteria for designation of nonbank financial companies as "systemically important"Analysis of Volcker Rule restrictions on proprietary trading and hedge fund activities by banking entitiesAnalysis of proposals by Financial Stability Oversight CouncilAnalysis of issues relating to "shadow banking system" Comment letter on Moody's proposal to revise rating criteria for money market fundsAnalysis of President's Working Group recommendations on money market fundsComment letter on FDIC proposal to extend guarantee of noninterest bearing transaction accountsAnalysis comparing broker-dealer suitability standard with trustee fiduciary standardAnalysis of SEC proposal to revise Rule 12b-1 mutual fund feesPaper on implications of Dodd-Frank Act for bank holding companiesAnalysis of various titles of Dodd-Frank Wall Street Reform and Consumer Protection ActPaper analyzing the reasonableness standard for service provider fees under the Employee Retirement Income Security Act (ERISA)Drafting legislative amendments to financial services reform legislationAnalysis of new Basel international liquidity framework for banksAnalysis of financial reform legislation Analysis of implications of new consolidated accounting rules (FAS 167) for bank capitalAdvice regarding FINRA rules on "parking" of brokerage license and applicability of certain FINRA rules to bank employees engaged in securities transactionsAnalysis of proposed Investor Protection Act of 2009 and related proposals Analysis of legislation proposed by Obama Administration to reform the financial regulatory systemAdvice for securities brokers on implications of fiduciary status under Investment Advisers Act of 1940Analysis of Administration proposal to impose a fiduciary duty on securities broker-dealersAnalysis of Financial Accounting Standards Board issuance on consolidated accounting (FAS 167) and implications for money market mutual funds Memorandum analyzing Treasury proposal to establish a regulatory mechanism for resolving failing financial companies Memorandum on meaning of "systemic risk" and proposals to address systemically significant financial institutionsMemorandum on Federal Reserve systemic oversight authority under "umbrella" regulation provisions of Gramm-Leach-Bliley Act
White paper on "The Truth About Money Funds"Critical analysis of Group of Thirty Report on Financial RegulationCritical analysis of Moody's and Fitch criteria for rating money market fundsMemorandum on Congressional financial reform activitiesMemorandum on fiduciary Investments in money market funds in a zero or negative interest rate environmentMemorandum on eligibility of certain financing arrangements for FDIC temporary liquidity guarantee programExpert witness report in litigation on bank commodity trading activitiesAdvice to financial industry trade association on regulatory reform proposals and issuesMemorandum on Emergency Economic Stabilization Act of 2008White paper examining causes and consequences of current financial crisis, the government’s response, and financial restructuring initiatives Memorandum on risk characteristics of certain money market mutual fundsWhite paper examining Federal Reserve Board authority to extend liquidity to broker-dealers and implications of Bear Stearns crisis for federal safety net and future financial regulation Memorandum on scope of coverage of various customer account arrangements under Treasury Department’s Temporary Guarantee Program for money market mutual funds Expert witness testimony in Financial Industry Regulatory Authority (FINRA) arbitration proceeding. Memorandum on applicability of various exemptions for banks from broker-dealer regulation under Regulation RMemorandum on exemption from Section 23A of the Federal Reserve Act for bank purchases of assets from affiliated money market mutual funds Advice concerning investment of trust assets in bank deposits Memorandum on FDIC pass-through insurance coverage for specific deposit account arrangements Advice on risk weightings of specific assets under Basel II capital standards Advice on scope of FDIC insurance coverage for sweep accounts in event of bank failure under new FDIC regulation Advice on rule proposal by Financial Industry Regulatory Authority to exempt bank dual employees from certain broker-dealer supervision requirements Memorandum on covered bonds as partial substitute for Fannie Mae and Freddie Mac debt Memorandum on risk characteristics of GSE debt in light of Housing and Economic Recovery Act of 2008 Advice on mutual fund filing fees under particular state laws Advice on state law requirements pertaining to solicitation of fiduciary business under reciprocal statutes of another stateMemorandum on conflicts of interest regulation applicable to broker-dealers and investment advisers
Memorandum on risk characteristics of certain money market mutual funds
Expert witness testimony in Financial Industry Regulatory Authority (FINRA) arbitration proceeding.